WAIDHAN ENGINEERING AND INDUSTRIES PVT. LTD.,SINGRAULI vs. DY. COMMISSIONER OF INCOME TAX, SATNA

ITA 179/JAB/2024Status: DisposedITAT Jabalpur20 August 2026AY 2016-1714 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the AO had failed to verify whether the repairs and maintenance provided an enduring benefit or were merely for the upkeep of existing machinery. The assessee successfully demonstrated that the expenditure was for the upkeep of machinery and buildings.

What were the facts?

The assessee claimed certain expenses as revenue expenditure for repairs and maintenance. The Assessing Officer (AO) treated these expenses as capital expenditure and made an addition to the assessee's total income. The CIT(A) upheld the AO's decision.

What were the issues?

Whether expenses incurred on repairs and maintenance of machinery and buildings are revenue or capital in nature, and whether the AO correctly distinguished between upkeep and enduring benefit.

Which sections of the Income-tax Act were involved?

Section 37

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH “DB”, JABALPUR

Before: SHRI KUL BHARAT & SHRI, GD PADMAHSHALI

For Appellant: Shri Sukesh Kumar, CA
For Respondent: Shri N. M. Prasad, Sr. CIT-DR-1

PER KUL BHARAT, VICE PRESIDENT.:

This appeal, by the assessee, is directed against the order of the learned Addl/Joint Commissioner of Income-tax (Appeals)- 1, Siliguri, dated 26.07.2024, pertaining to the assessment year 2016-17. The assessee has raised the following grounds of appeal: -

“1. The learned CIT (Appeal) failed to consider the Accounting Standard (AS) 10 Property, Plant and Equipment issued by The Institute of chartered accountants of India.

2.

The learned CIT (Appeal) failed to consider that no particular discrepancy was found in the books and records and supporting maintained in the regular course of business.

The order continues below.

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